Sipos and Marsden (No 2)
[2015] FamCA 883
•21 September 2015
FAMILY COURT OF AUSTRALIA
| SIPOS & MARSDEN (NO 2) | [2015] FamCA 883 |
FAMILY LAW – CHILDREN – With whom a child lives – with whom a child spends time – with whom a child communicates – Orders that child live with father and spend supervised time with mother and at such other times as agreed – Order that mother communicate with the child via skype or telephone once a month and on special occasions and send gifts and cards
| Family Law Act 1975 (Cth) ss 60B,60CC (1),(2) and (3) Mauldera & Orbel (2014) FLC 93-602 | ||
| APPLICANT: | Mr Sipos | |
| RESPONDENT: | Ms Marsden |
| INDEPENDENT CHILDREN’S LAWYER: | Legal Aid Commission |
| FILE NUMBER: | SYC | 6391 | of | 2012 |
| DATE DELIVERED: | 21 September 2015 |
| PLACE DELIVERED: | Hobart |
| PLACE HEARD: | Hobart |
| JUDGMENT OF: | Benjamin J |
| HEARING DATE: | 21 September 2015 |
REPRESENTATION
| COUNSEL FOR THE APPLICANT: | Mr Sipos in person |
| SOLICITOR FOR THE APPLICANT: |
| COUNSEL FOR THE RESPONDENT: | No appearance |
| SOLICITOR FOR THE RESPONDENT: |
| COUNSEL FOR THE INDEPENDENT CHILDREN’S LAWYER: | Mr Bearman |
| SOLICITOR FOR THE INDEPENDENT CHILDREN’S LAWYER: | Legal Aid Commission Tasmania |
Orders
Orders be made in terms of Exhibit “1” prepared and tendered by the Independent Children’s Lawyer, an engrossed copy attached hereto and marked Exhibit “1”.
Pursuant to s 65DA(2) and s 62B, the particulars of the obligations these orders create and the particulars of the consequences that may follow if a person contravenes these orders and details of who can assist parties adjust to and comply with an order are set out in the Fact Sheet attached hereto and these particulars are included in these orders.
All extant applications be dismissed except costs applications, if any, which are to be dealt with in accordance with the Family Law Rules 2004 (Cth).
IT IS DIRECTED
All subpoenaed documents be returned to the persons or institutions from which they emanated and all exhibits are returned to the person or persons who tendered the same, with the exception of Exhibit “1” from today.
The Independent Children’s Lawyer forward to my administrative associate the form of order in Exhibit “1”, in electronic word format, within one (1) business day of today’s date.
IT IS CERTIFIED
Pursuant to Rule 19.50 of the Family Law Rules 2004 it was reasonable to engage counsel to attend.
IT IS NOTED that publication of this judgment by this Court under the pseudonym Sipos & Marsden (No. 2) has been approved by the Chief Justice pursuant to s 121(9)(g) of the Family Law Act 1975 (Cth).
Exhibit “1”
All extant parenting Orders be discharged.
[Mr Sipos] ("the Father") have sole parental responsibility for the child [B] born … 2010 ("the child")
IT IS NOTED
The Father will advise [Ms Marsden] ("the Mother") of any decisions to be made relating to the child’s medical, educational, religious and sporting involvement and seek her input about those decisions & otherwise that this Order acts as an Authority for the Mother to speak with and obtain any information from any person, organisation, school and the like who is involved with the child.
The child live with the Father.
The Mother spend time with the child as follows:-
(a)at the Hobart Children's Contact Service on dates and times as directed by that Service & that time occur no more than 4 times a year with the Mother to provide notice of her intention to spend time at least 28 days before that time by email to the Father;
(b)any other time as agreed in writing between the Mother and the Father;
The Mother communicate with the child by Skype or telephone as follows;
(a)the first Sunday of each month at 5.30p.m. commencing Sunday 4 October 2015;
(b)on the child's birthday, the Mother's birthday, Mother's Day, Easter Sunday and Christmas Day as agreed but, failing agreement, at 5.30p.m. those days.
(c)such other times as agreed in writing
The parties communicate by email in relation to the child or such other manner as agreed in writing by the parties.
Each party advise the other party as soon as practicable of that parties current email and telephone numbers and the mother keeps the father informed as to her current residential address.
The mother not denigrate or abuse the Father, [Ms C] or any of the paternal family in the presence of the child or at all.
The mother be permitted to send any gifts, cards or letters to the child & the Father be permitted to read /inspect such material before considering to provide it to the child.
| FAMILY COURT OF AUSTRALIA AT HOBART |
FILE NUMBER: SYC 6392 of 2012
| Mr Sipos |
Applicant
And
| Ms Marsden |
Respondent
REASONS FOR JUDGMENT
INTRODUCTION
These are proceedings between Mr Sipos (‘the father’) and Ms Marsden (‘the mother’) in relation to the parenting arrangements in respect of the child who was born in 2010 (‘the child,’) who is five years of age. The parties have been engaged in litigation with regard to the child for some time and he has had a fairly traumatic time, particularly over the last 12 months.
The father seeks orders that the child live with him and that he have sole parental responsibility. He seeks further orders that the mother spend time with the child, but that such time be supervised by the Hobart Children’s Contact Centre or such other arrangements as is agreed to in writing between the parties. He seeks orders that the child communicate with his mother on various occasions, regular occasions, Mother’s Day, the mother’s birthday, Easter Sunday and Christmas Day.
The father also seeks orders that the parties communicate between themselves by email in relation to the child, and that the mother advise the father of her current electronic addresses. In addition, he seeks orders that the mother not denigrate him or his partner, Ms C, and that the mother be permitted to send cards and letters to the child.
The mother has had somewhat of an unusual approach in respect of parenting the child. She had endeavoured at times to co-parent and on occasions to exclude the father from the child’s life. In an affidavit, filed last Friday, the mother seeks simply to spend time with the child and expresses her frustration with the legal system. Of that I will discuss later in these reasons.
BACKGROUND
The father is aged 35. The mother is aged 39. The parties commenced cohabitation in about 2008, and in 2010 the child was born. The parties separated in June 2010. In 2010 or 2011 the father and Ms C (‘the father’s partner’) commenced a relationship. That has been the source of some unhappiness, or expressed unhappiness, for the mother over a period of now almost five years.
In June 2012 the parties agreed that the child would spend four days out of 10 with the father. In August 2012 this was reduced by the mother, apparently unilaterally, to two days out of 12. In October 2012 the mother unilaterally relocated with the child to E Town in New South Wales. The mother filed initiating proceedings in then Federal Magistrates Court, and eventually in December of that year the proceedings were transferred to Tasmania. In January of that year the mother returned to Tasmania, and the changeovers were to occur at the Hobart Children’s Contact Service.
At that time complaints were made against the father, and the matter was placed in the Magellan list of the Family Court. It was removed from the Magellan list in May 2013.
In July 2013 the mother again relocated to E Town in New South Wales. However, the child was left in the primary care of the father. Final orders were made by consent for the child to live with his father and spend one half of each of the school holiday periods with the mother.
In February 2014 the mother returned to Tasmania, and the parties attended mediation but no agreement was reached. In July 2014 the father filed initiating proceedings seeking orders that the child live with him and spend some time with the mother. The mother responded with an application for orders that the child live with each parent on week about arrangement. It is significant to note that, but for a period in E Town earlier this year, the child has lived in the care of the father and his partner since about July 2013.
In 2013 a child, of the father and the father’s partner, F was born, and the matter came before me on 29 January 2015.
In January 2015, when the matter came before me, I listed the matter for final hearing in September of this year, and the parties agreed that the child would spend time with the mother on a regular fortnightly basis.
In March 2015 the child was spending time with the mother and failed to return the child to the father’s care in breach of orders made in this Court and the arrangement between the parties. A recovery order was made, and eventually the child was recovered from the care of the mother in March 2015 in circumstances which, given the evidence, are quite troubling. This has, from the evidence of Ms G (‘the Family Consultant’), had an adverse impact upon the child.
These proceedings are listed for hearing today and the mother has filed a notice of discontinuance. She filed an affidavit at court last Friday in which she noted that these proceedings were to be heard today. In that affidavit the mother notes she filed a notice of discontinuance, says that she has endeavoured to negotiate with the father and has no legal representation. That has significant echoes of expressions of difficulties in getting legal representation which she made to this Court earlier next [sic] year after the recovery orders.
The mother has had the opportunity to become involved in these proceedings but has, in a direct sense, chosen not to do so by filing the notice of discontinuance. Her affidavit, in some respects, reflects the concerns set out by the Family Consultant in her later report as to the mother’s lack of insight into her own approach to parenting of this child. The mother complains that she has had no contact with the child and yet contact was available to her, although in a supervised capacity, given the removal of the child from Tasmania earlier this year.
The father relies upon his initiating application, filed 22 July 2014, and his affidavit filed 21 April 2015. The father also relies upon the affidavit of his partner, filed the same day. I have read those affidavits and note that they have been seriously challenged at times in some respects by the mother. However, she is not here to prosecute that today. In many ways it reflects the mother’s anxiety about the father’s relationship with his partner which has been the subject of discussions. The evidence of the father’s partner and the father is part of the material upon which I have made this determination.
The Independent Children's Lawyer provided a case summary, produced the notice of discontinuance of the mother filed 16 July 2015; and relied upon the Family Report prepared in April 2013, the Family Report prepared by the Family Cousultant dated October 2014, and her subsequent report dated 31 July 2015.
In her 2014 Children and Parents Issues Assessment, the Family Consultant saw the father, the father’s partner and the mother. She was concerned about the demeanour of the mother in terms of her presentation. She was concerned that:-[1]
…[The mother] might foster an overly and enmeshed relationship with [the child] ...
[1] At paragraph 56 of the Family Report dated 9 April 2013.
The Family Consultant observes, on page 7 of the 2014 Children and Parents Issues Assessment:-
…The mother appears to have significant difficulty coming to terms with her separation from the father and that another woman (the father’s partner) is helping to parent her son. In addition, she either misunderstood various legal processes or minimised her role in making decisions, to justify her subsequent actions. …
The Family Consultant observes that the mother is likely to benefit from ongoing counselling. She says that the mother has demonstrated good skills in interacting with her son, but needs to moderate her expectations and behaviour and keep commonly accepted boundaries between her and the father.
The Family Consultant’s expert assessment indicated that a mental health assessment of the mother may be needed to ascertain whether the mother has any underlying mental health problems. At that time, and this was before the child had been removed from Tasmania, the Family Consultant suggested that the child spend two nights a week with the mother during school term, part of the school holidays, that the mother have therapeutic counselling and that any professional assisting the mother be permitted to read the report. She suggested this as a temporary arrangement.
In her final Family Report, the same Family Consultant observed, firstly at paragraph 26:-[2]
…the proposals of [the mother] concerning [the child’s care] had varied. Her actions have not always been congruent with her [the mother’s] previous behaviour …
[2] Dated 3 August 2015.
She noted the discussions in 2014 of equal time and that the mother did not participate in that report. The Family Consultant noted that the time the child was removed from Tasmania, the mother had ample knowledge of the need to comply with Court orders and noted the actions would have caused a great deal of distress to the child and placed him at physical risk, particularly having regard to the material provided by the police.
The Family Consultant was concerned that the mother had limited insight, if any insight, into the harm her actions could have caused the child, including how she placed the child and how she concealed the child, which may have caused him harm or worse.
It also showed that the mother demonstrated what is described as:-[3]
…a wanton disregard about the emotional and financial impact on the father and [his partner] of her unilateral action of retaining and hiding [the child]. …
[3] Ibid at paragraph 33.
When the child was returned, the mother threatened the father and his partner.
There are no serious criticisms about the father’s care of the child. I accept that evidence.
THE LAW
The provisions of the Family Law Act that deals with children is set out in Part VII of the Act, in particular s 60B articulates the objects and the principles underlying them as follows:-
(1) The objects of this Part are to ensure that the best interests of children are met by:
(a) ensuring that children have the benefit of both of their parents having a meaningful involvement in their lives, to the maximum extent consistent with the best interests of the child; and
(b)protecting children from physical or psychological harm from being subjected to, or exposed to, abuse, neglect or family violence; and
(c) ensuring that children receive adequate and proper parenting to help them achieve their full potential; and
(d) ensuring that parents fulfil their duties, and meet their responsibilities, concerning the care, welfare and development of their children.
(2) The principles underlying these objects are that (except when it is or would be contrary to a child’s best interests):
(a) children have the right to know and be cared for by both their parents, regardless of whether their parents are married, separated, have never married or have never lived together; and
(b) children have a right to spend time on a regular basis with, and communicate on a regular basis with, both their parents and other people significant to their care, welfare and development (such as grandparents and other relatives); and
(c) parents jointly share duties and responsibilities concerning the care, welfare and development of their children; and
(d) parents should agree about the future parenting of their children; and
(e) children have a right to enjoy their culture (including the right to enjoy that culture with other people who share that culture).
A statutory presumption, albeit a rebuttable presumption, is created by s 61DA(1) of the Act. It sets out that ‘it is in the best interests of the child for the child's parents to have equal shared parental responsibility for the child’. The presumption does not apply if there are reasonable grounds to believe that a parent of the child, or a person who lives with a parent of the child, has engaged in either abuse of the child or another child who, at the time, was a member of the parent’s family, or that other person’s family, or family violence. The section also provides that the presumption may be rebutted if the court is satisfied that an order for equal shared parental responsibility would not be in the best interests of the child.
The torturous terminology of the section is thus that the court is to presume that it is in the best interests of the child for his/her parents to have equal shared parental responsibility unless the court is satisfied that it would not be in the in the child’s best interest for the parents to have equal shared parental responsibility.
If an order is made providing that a child’s parents have equal shared parental responsibility, either pursuant to the presumption or otherwise:-
(a)Section 65DAA(1) of the Act obliges the Court consider, in the context of the child’s best interest, making an order or provision in an order for the child to spend equal time with each of the parents, provided such arrangement is reasonably practicable, and if not;
(b)Section 65DAA(2) of the Act obliges the Court consider, in the context of the child’s best interest, making an order or provision in an order for the child to spend substantial and significant time with each of the parents, provided such arrangement is reasonably practicable.
(c)In the context of these determinations, section 65DAA(3) sets out some parameters in considering the term ‘substantial and significant time’ and section 65DAA(5) sets out the factors which a court must consider when determining the question of ‘reasonably practicality’.
The next step in the statutory path is contained in s 60CA, which provides that in deciding whether to make a particular parenting order the Court must regard the best interests of the child as the paramount consideration and consequently in determining the child’s best interests the court must consider the matters set out in s 60CC.
In Mauldera & Orbel (2014) FLC 93-602 the Full Court discussed the relationship between the objects contained in s 60B and the factors which must be considered in s 60CC, concluding that the objects are able to be used to aid in the construction of words of the legislation, but cannot be used to undermine the plain and unambiguous requirement to consider the factors contained in s 60CC to determine the child’s best interests. The section relevantly provides:-
(1)Subject to subsection (5), in determining what is in the child's best interests, the court must consider the matters set out in subsections (2) and (3).
(2)The primary considerations are:
(a) the benefit to the child of having a meaningful relationship with both of the child's parents; and
(b)the need to protect the child from physical or psychological harm from being subjected to, or exposed to, abuse, neglect or family violence.
Note: Making these considerations the primary ones is consistent with the objects of this Part set out in paragraphs 60B(1)(a) and (b).
(2A)In applying the considerations set out in subsection (2), the court is to give greater weight to the consideration set out in paragraph (2)(b).
(3)Additional considerations are:
(a)any views expressed by the child and any factors (such as the child's maturity or level of understanding) that the court thinks are relevant to the weight it should give to the child's views;
(b) the nature of the relationship of the child with:
(i) each of the child's parents; and
(ii) other persons (including any grandparent or other relative of the child);
(c) the extent to which each of the child's parents has taken, or failed to take, the opportunity:
(i) to participate in making decisions about major long-term issues in relation to the child; and
(ii) to spend time with the child; and
(iii) to communicate with the child;
(ca) the extent to which each of the child's parents has fulfilled, or failed to fulfil, the parent's obligations to maintain the child;
(d)the likely effect of any changes in the child's circumstances, including the likely effect on the child of any separation from:
(i) either of his or her parents; or
(ii) any other child, or other person (including any grandparent or other relative of the child), with whom he or she has been living;
(e) the practical difficulty and expense of a child spending time with and communicating with a parent and whether that difficulty or expense will substantially affect the child's right to maintain personal relations and direct contact with both parents on a regular basis;
(f) the capacity of:
(i) each of the child's parents; and
(ii)any other person (including any grandparent or other relative of the child);
to provide for the needs of the child, including emotional and intellectual needs;
(g)the maturity, sex, lifestyle and background (including lifestyle, culture and traditions) of the child and of either of the child's parents, and any other characteristics of the child that the court thinks are relevant;
(h) if the child is an Aboriginal child or a Torres Strait Islander child:
(i)the child's right to enjoy his or her Aboriginal or Torres Strait Islander culture (including the right to enjoy that culture with other people who share that culture); and
(ii)the likely impact any proposed parenting order under this Part will have on that right;
(i)the attitude to the child, and to the responsibilities of parenthood, demonstrated by each of the child's parents;
(j)any family violence involving the child or a member of the child's family;
(k) if a family violence order applies, or has applied, to the child or a member of the child's family any relevant inferences that can be drawn from the order, taking into account the following:
(i) the nature of the order;
(ii) the circumstances in which the order was made;
(iii) any evidence admitted in proceedings for the order;
(iv) any findings made by the court in, or in proceedings for, the order;
(v) any other relevant matter;
(l)whether it would be preferable to make the order that would be least likely to lead to the institution of further proceedings in relation to the child;
(m) any other fact or circumstance that the court thinks is relevant.
I need to put in place arrangements which meet the best interests of this child. The child has been in a nurturing environment since moving into the care of the father. He has a meaningful relationship with both of his parents. That relationship with the mother has been maintained, notwithstanding the care of the child by the father and his partner. That reflects well on their parenting.
It is of value for this child to have a continuing relationship with the mother, provided he is safe and not exposed to the dramas and the risks to which he was exposed earlier this year.
In terms of section 60CC(2)(b) of the Act, the need to protect the child from psychical or psychological harm or being subjected to or exposed to abuse, neglect of family violence, the mother raised allegations in 2012, in which she suggested that the child was abused in the father’s care. The Family Consultant, in her Children and Parents Issues Assessment observed:-[4]
…[The mother] held these concerns when she was interviewed in 2013. When interviewed for this assessment. When interviewed for this assessment, [the mother] reported that she had been misled by her legal counsel in making these allegations. She now stated that she believes [the child] witnessed sexual activity between the father and [his partner], rather than having him having been abused.
[4] At page 1, paragraph 2, lines 4 to 8.
The mother has no concerns that the child is at risk in the care of the father having left the child in his full-time care, by way of consent orders some years ago.
In her most recent report, the Family Consultant outlines significant concerns of the child’s treatment by the mother and I note and accept the submissions of the Independent Children’s Lawyer on page 7, 8 and part of 9 in his submissions.[5]
[5] Filed the 16 September 2015.
Those concerns are serious. The consequence of that is that any arrangements at present with the child spending time with the mother need to be properly and effectively monitored. The child cannot be left in the unsupervised care of the mother at this time. That may change as the child gets older and becomes more independent. That will be a matter for the father as time progresses and as, hopefully, some trust restores between he and the mother, but that will take years, not months.
The child has given views as to the outcome of these proceedings, and I note the submission made by the Independent Children’s Lawyer in that respect. Given the age and maturity of the child, it is really a matter for this Court or the child’s parents rather than to rely upon what the child says, although the Court is somewhat comforted that the child, although wishing to see his mother, is quite comfortable and thriving in his current circumstances. The child has a very close relationship with his father, his partner and his siblings. The child has a good relationship with his mother; to which I have alluded earlier, but it needs to be properly managed and monitored.
In terms of section 60CC(3)(c) of the Act, the father has facilitated and encouraged a continuing relationship between the child and the mother. It cannot be said the opposite way round. The mother initially adopted a view that the child was hers and endeavoured to exclude the father in a number of ways from the child’s life. That reached a crescendo earlier this year; to which I have already referred.
In terms of section 60CC(3)(ca) of the Act, the extent to which each child’s parents have fulfilled or failed to fulfil their obligations, both parents have maintained the child, although in recent times the father has been primarily economically responsible for the child. There will be no change in the child’s circumstances by way of the orders I have made except that the time with the mother will be supervised until such time as either a court or the father determine that it is safe for the child to spend unsupervised time with the mother.
In terms of section 60CC(3)(e) of the Act, there are practical difficulties with the child spending time with his mother. The mother is clearly attached to her family in the E Town area and has endeavoured to relocate there on at least two occasions with the child. It is geographically difficult for the mother to get to Tasmania. It would involve, at best, a flight to Sydney and then a flight from Sydney to Hobart and for the mother to organise accommodation in Hobart. It will be difficult for her, although not impossible for her.
As to the capacity of each of the parents, each has a capacity to meet the physical needs of the child, although clearly the father’s, given the history provided, is superior to that of the mother’s.
Section 60CC(3)(g) of the Act is not a relevant consideration, nor is section 60CC(3)(h).
In terms of the attitude to the child and the responsibilities of parenthood, the father has demonstrated a strong and clear child-focused attitude. The mother has at times seemed impulsive and placed the child in danger. She has endeavoured to exclude the child from the father’s care.
There are no relevant considerations as to family violence.
In terms of the child, it is necessary to bring these proceedings to an end. This child is some five years old and has spent about three and a half of those five years with his life being determined by strangers such as this judge who will never know that child as well as his parents know him. It needs to come out of the Court and allow this child to spend the rest of his childhood in peace and quiet, hopefully, knowing both parents in a safe, secure way. The only way that can occur is by way of the orders recommended by the Independent Children’s Lawyer.
In terms of parental responsibility and having regard to the section 60CC factors to which I have alluded in the evidence, this is not a case where there can even be considered equal shared parental responsibility. It would leave the child in an impossible circumstance where decisions have to be made between a mother who has significant animosity towards the father and his partner and has adopted unilateral approaches with regard to the child. This child needs certainty in relation to the major long-term issues such as health, education and the like. To make an order for either equal shared parental responsibility or, worse still in this case, several parental responsibility in which case each parent would have parental responsibility, and they could act, not in concert, but in opposition to each other, would be unfortunate for this child. Accordingly, the only sensible solution for this child in these circumstances is that the father will have parental responsibility, and, sensibly, the father agrees with the submissions of the Independent Children’s Lawyer that he keeps the mother informed of any such major decisions or facts in respect of the child.
The child has lived with the father, is settled and thriving in the father’s household, and he should continue to do so. What then should happen in terms of the time the child spends with the mother? This is not a case where there ought not to be any time. This is a case where there ought to be time, but it needs to be time where the child is safe and feels safe and knows that when he sees his mother he’s not at risk of being separated from his father and his father’s broader family. It is suggested that this occurred at the Hobart Children’s Contact Service, and I agree with that approach. The mother will not be happy with that, but the child will, and it will provide security for the father and his broader family and, more importantly, for the child.
The orders sensibly provide that these times can be changed by agreement between the mother and the father. What invariably happens is as children get older they become inquisitive about a parent they haven’t seen. The father has demonstrated a fairly practical approach no doubt with the influence of his partner who I think has been here most of the time. She has been, in my view, an influence in a positive way in the life of the father and, more importantly, the life of this child. I am comforted in making that order to know that the father will not unreasonably withhold the child from the mother as he gets older and as, hopefully, the mother better understands the circumstances in which she has placed herself.
There ought to be communication, and that’s suggested by the Independent Children’s Lawyer to be the first Sunday of each month and other occasions make sense as a starting point. I have no doubt that this child as he becomes more technologically savvy and no doubt overtakes the father in his father’s household within the next year or so, if that has not already occurred, will find ways to speak with his mother, and that ought to be encouraged, provided it is constructive and meets the needs of the child. It is important that the parties communicate, but, given the mother’s anger at the relationship breakdown and concerns about the father’s partner, communication by email in respect of the child probably seems at this stage an appropriate way to do things, and, as such, each should provide the other with their email addresses and telephone numbers.
Given the concerns with regard to the mother and her view of the relationship between the father and his present partner, the injunction to protect the child from abuse of the father or his partner in the child’s presence makes sense, as does the order regarding the sending of presents and cards. Having considered all those matters, I make those orders. I will vary the orders a little bit to provide that order 6, that the parties communicate by email in relation to the child or such other manner as is agreed in writing between the parties. Order 7 should read that each party advise the other party as soon as practicable of that party’s email address and telephone numbers and that the mother keeps the father informed as to her current residential address.
Paragraph 5 should have added to it subparagraph (c): such other times as agreed in writing between the mother and father, so that’s the case in relation to time. It will also be the case in relation to communication. So if you change the communication timetable, as long as it is in writing that will operate.
I certify that the preceding fifty three (53) paragraphs are a true copy of the reasons for judgment of the Honourable Justice Benjamin delivered on 21 September 2015.
Associate:
Date: 21 September 2015
Key Legal Topics
Areas of Law
-
Family Law
-
Civil Procedure
Legal Concepts
-
Costs
-
Procedural Fairness
-
Remedies
0
0
0